Practical European Tax Strategies

Only Practical European Tax Strategies delivers expert insight into the proven strategies your colleagues are using to minimize their tax liability in the European markets. Every month, Strategies delves into how the region's tax developments will affect your organization ... and what you can do about it right now. To Subscribe>
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Download PDF of June 2010 Issue of Practical European Tax Strategies
16 Aug 2010

In This Edition

Planning Perspective
Regional--Tax Planning: The Current State of Play on Substance; A Plea to Monitor Geographically-Dispersed Corporate Brainpower
By Axel Smits and Isabel Verlinden (Pricewaterhouse- Coopers, Belgium) p. 2

Special Interview
Saving Taxes and Protecting Investments: Investing in Latin America through a Spanish ETVE
An Interview with Carlos Durán (Uría Menéndez) p. 3

EU--ECJ: Anti-abuse Provision Merger Directive Limited to Income Tax
By Marc De Munter (DLA Piper UK LLP) p. 4

Belgium--Belgian Taxation of Non-Resident Investment Companies Contrary to EU Law?
By Patrick Smet and Christopher Thompson (Allen & Overy LLP) p. 4

Italy--Italy Introduces New Legislation on Transfer Pricing Documentation
By Mario Martinelli (McDermott Will & Emery Studio Legale Associato) p. 6

Russia--Debt Forgiveness: Tax Treatment and Consequences
By Maria Semina and Irina Babeshko (Ernst & Young) p. 8

Highlights

Trends in Monitoring Economic Substance for Tax Planning Purposes
Tax departments should review their strategies, including transfer pricing, to address substance issues, which are becoming of greater concern to tax authorities around the world. Instead of asking “How many people do I need to move?” the question should rather be: “What am I trying to achieve?” Page 2

Saving Taxes Through the Spanish ETVE
Firms establishing subsidiaries in Latin America often funnel investments and returning profits through Spanish holding companies. In a special interview, Strategies examines the use and benefits of the Spanish ETVE. Page 3

Debt Forgiveness in Russia
The tax implications of debt forgiveness in Russia are a long-standing source of controversy. Frequently the tax authorities try to challenge the deduction of write-offs that arise from debts that are forgiven by mutual agreement of the parties. A recent ruling of the Supreme Arbitration Court addresses a situation in which a trade debt had been partially forgiven in the course of court proceedings. Page 8

Italy Introduces New Transfer Pricing Rules
Companies operating in Italy will need to make significant efforts in the coming months to comply with new Italian rules on transfer pricing documentation. Page 6

Practical European Tax Strategies Issue Archives
15 Apr 2008

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